Definition
As used in law, "store" carries two distinct meanings depending on context — one as a noun, one as a verb — and the two interact in commercial and insurance law.
1. (noun) A place where goods are kept for deposit and safekeeping, or where goods are offered for sale. At common law, the term was applied to both a warehouse or place of deposit (the older English usage) and a retail or wholesale establishment for the sale of merchandise (the American usage). Modern American law uses the term primarily in the commercial sense — a retail or wholesale shop — but the custodial sense persists in storage, warehousing, and insurance contexts.
2. (verb — "to store") To keep merchandise for safe custody, with the expectation that the goods will be returned or delivered in the same condition as when received. The defining characteristic is that safekeeping is the primary object: the person receiving the goods is not expected to consume them, sell them, or treat them as their own. This function aligns with the law of bailment.
Common Language
Modern common usage (Wiktionary): A place where items may be purchased; also a supply held in storage, a great quantity, or a place where things are routinely kept.
Historical common usage (Webster's 1913): A place of deposit for goods, especially in large quantities; a storehouse or warehouse; also any place where goods are kept or sold.
The gap matters primarily in insurance and bailment contexts. When a policy covers loss of goods "in store" or "while stored," courts have looked to the legal meaning of "storing" — safekeeping as the primary purpose — rather than the casual meaning of simply placing something somewhere. An insured who deposits goods at a warehouse for safekeeping is "storing" in the legal sense; a merchant who keeps goods on a shelf awaiting sale may not be, because the primary object is sale rather than custody.
Common Confusion
The noun "store" as a sales establishment and the verb "to store" as a custodial act are grammatically related but legally distinct. In insurance policy disputes, courts have repeatedly been required to determine whether goods were "stored" (custodial bailment, primary object being safekeeping) or merely present in a commercial store (primary object being sale). The two concepts converge when a retailer also warehouses surplus inventory; courts focus on the dominant purpose of the deposit to resolve ambiguity.
Why It Matters in Research
The Anglo-American divergence documented in Anderson's is practically significant when researching nineteenth-century sources. English cases and statutes using "store" almost always mean a warehouse or place of deposit, not a retail shop. American cases from the same period use "store" for both. Researchers working with insurance policy litigation from the 1800s — particularly fire insurance — will find that the operative question is almost always whether the "storing" definition is satisfied: was safekeeping the primary object? This framing derives from the New York cases cited in both editions of Black's and carries forward into modern warehousing law.
In statutory research, "store" appears in licensing and zoning codes (liquor store, retail store, general store) in the commercial sense, and in commercial code provisions governing warehouse receipts and storage bailments in the custodial sense. These are functionally separate bodies of law. Cross-referencing between them without awareness of this distinction is a frequent source of analytical error.
The "public store" fragment in Black's 2nd edition — cut off in the source — refers to government-maintained warehouses used for customs, military, or administrative purposes. This meaning appears in federal revenue and customs statutes and is distinct from both the retail and private storage senses.
Historical Dictionary Support
All four source dictionaries agree on the core structure: "store" as a noun covers both warehouse and shop; "to store" as a verb means custodial safekeeping with an obligation to return goods in the same condition. The agreement across Black's (both editions), Anderson's, and Bouvier's on the verbal definition — and their shared reliance on the same New York authorities — reflects that by the late nineteenth century this definition was settled.
Anderson's is the most useful source here because it explicitly flags the jurisdictional divergence between English and American usage of the noun form, a distinction the other dictionaries note only implicitly. Bouvier's adds the reference to Mississippi authority for the noun definition, indicating the American retail-store meaning was recognized across jurisdictions by the 1890s.
What none of the historical dictionaries adequately address is the modern proliferation of "store" in data and information contexts — "data store," "memory store" — which appears in Wiktionary but has no footprint in the classical legal dictionaries. Researchers working with technology law or electronic records statutes should not rely on these historical definitions for that usage.
Jurisdictional Note
The distinction between English and American usage of the noun "store" is most significant in interpreting pre-twentieth-century sources and contracts. Modern American jurisdictions are uniform in recognizing both the custodial and retail senses, but statutory definitions in specific regulatory contexts (zoning, liquor licensing, retail sales tax) may control which meaning applies within that framework.
Encyclopedia Cross-Reference
Law Mind Encyclopedia — Bailment (for the custodial "storing" function and obligations of the storer)
Law Mind Encyclopedia — Warehousing and Storage (for warehouse receipts, public warehouses, and the public store concept)
Law Mind Encyclopedia — Commercial Sales (for the retail store context and sale of goods at the place of business)